1 Privacy Policy

1. 1.1 Mitsubishi Electric Europe B.V., together with other members of its group (MEU, we/us/our) are committed to safeguarding the privacy of our customers and users (you/your) who visit our websites (the Websites). This privacy policy (the Privacy Policy) sets out our personal data collection and sharing practices for our websites and is intended to inform you of the ways in which the Websites collect personal data, the uses of that personal data and the ways in which we will share any personal data you choose to provide to us.
2. 1.2 If you are an existing customer of ours, further details about how we use your personal data is set out in your customer contract with us. Further notices highlighting certain uses we wish to make of your personal data together with the ability to opt in or out of selected uses may also be provided when we collect personal data from you.
3. 1.3 Our websites may contain links to other third party websites. If you follow a link to any of those third party websites, please note that they have their own privacy policies and that we do not accept any responsibility or liability for their policies or processing of your personal data. Please check these policies before you submit any personal data to such third party websites.
4. 1.4 This Privacy Policy is intended to explain our privacy practices and covers the following areas :
   1. (a) What personal data about you we may collect
   2. (b) How we may use your personal data
   3. (c) How we protect your personal data
   4. (d) Contacting us & your rights to object to marketing and to access and update your personal data
   5. (e) Our Cookies Policy
   6. (f) How changes to this Privacy Policy and the Cookies Policy will be made

2 Information we may collect about you

1. 2.1 We will collect and process all or some of the following personal data about you :
   1. (a) Information you provide to us
      Personal data that you provide to us, such as when using the contact form on our websites, including your name, email address, and other contact details;
   2. (b) Our correspondence
      If you contact us, we will typically keep a record of that correspondence;
   3. (c) Survey information
      We may also ask you to complete surveys that we use for research purposes. In such circumstances we shall collect the information provided in the completed survey;
   4. (d) Website and communication usage
      Details of your visits to the websites and information collected through cookies and other tracking technologies including, but not limited to, your IP address and domain name, your browser version and operating system, traffic data, location data, web logs and other communication data, and the resources that you access.

3 Uses made of your personal data

1. 3.1 In this section, we set out the purposes for which we use personal data that we collect via our websites and, in compliance with our obligations under European law, identify the “legal grounds” on which we rely to process the information.
2. 3.2 These “legal grounds” are set out in European Data Protection Law, which allows companies to process personal data only when the processing is permitted by the specific “legal grounds” set out in law (the full description of each of these grounds can be found here).
3. 3.3 Please note that in addition to the disclosures we have identified below, we may disclose personal data for the purposes we explain in this notice to service providers, contractors, agents, advisors (e.g. legal, financial, business or other advisors) and affiliates of MEU that perform activities on our behalf, as well as other members of the Mitsubishi Electric group.
   1. (a) To communicate effectively with you and conduct our business
      To conduct our business, including to respond to your queries, to otherwise communicate with you, or to carry out our obligations arising from any agreements entered into between you and us;
      Use justification:
      contract performance, legitimate interests (to enable us to perform our obligations and provide our services to you)
   2. (b) To provide you with marketing materials
      To provide you with updates and offers, where you have chosen to receive these. We may also use your information for marketing our own and our selected business partners’ products and services to you by post, email, SMS, phone and fax and, where required by law, we will ask for your consent at the time we collect your data to conduct any of these types of marketing. We will provide an option to unsubscribe or opt-out of further communication on any electronic marketing communication sent to you or you may opt out by contacting us through the “General Data Protection Enquiry” form below.
      Use justification:
      consent, legitimate interests (to keep you updated with news in relation to our products and services)
   3. (c) For research and development purposes
      To analyse your personal data in order to better understand your and our other clients’ services and marketing requirements, to better understand our business and develop our products and services;
      Use justification:
      legitimate interests (to allow us to improve our services)
   4. (d) To monitor certain activities
      To monitor queries and transactions to ensure service quality, compliance with procedures and to combat fraud;
      Use justification:
      legal obligations, legal claims, legitimate interests (to ensure that the quality and legality of our services)
   5. (e) To inform you of changes
      To notify you about changes to our services and products;
      Use justification:
      legitimate interests (to notify you about changes to our service)
   6. (f) To ensure website content is relevant
      To ensure that content from our websites is presented in the most effective manner for you and for your device, which may include passing your data to business partners, suppliers and/or service providers;
      Use justification:
      legitimate interests (to allow us to provide you with the content and services on the websites)
   7. (g) To reorganise or make changes to our business
      In the event that we: (i) are subject to negotiations for the sale of our business or part thereof to a third party; (ii) are sold to a third party; or (iii) undergo a re-organisation, we may need to transfer some or all of your personal data to the relevant third party (or its advisors) as part of any due diligence process for the purpose of analysing any proposed sale or re-organisation. We may also need to transfer your personal data to that re-organised entity or third party (or their advisors) after the sale or reorganisation for them to use for the same purposes as set out in this policy.
      Use justification:
      legitimate interests (in order to allow us to change and run our business)
   8. (h) In connection with legal or regulatory obligations
      We may process your personal data to comply with our regulatory requirements or dialogue with regulators as applicable which may include disclosing your personal data to third parties, the court service and/or regulators or law enforcement agencies in connection with enquiries, proceedings or investigations by such parties anywhere in the world or where compelled to do so. Where permitted, we will direct any such request to you or notify you before responding unless to do so would prejudice the prevention or detection of a crime.
      Use justification:
      legal obligations, legal claims, legitimate interests (to cooperate with law enforcement and regulatory authorities)

4 Transmission, storage and security of your personal data

Security over the internet

1. 4.1 No data transmission over the Internet or website can be guaranteed to be secure from intrusion. However, we maintain commercially reasonable physical, electronic and procedural safeguards to protect your personal data in accordance with data protection legislative requirements.
2. 4.2 All information you provide to us is stored on our or our subcontractors’ secure servers and accessed and used subject to our security policies and standards.

Export outside the EEA and UK

1. 4.3 Your personal data may be accessed by staff or suppliers in, transferred to, and/or stored at, a destination outside the country in which you are located, whose data protection laws may be of a lower standard than those in your country. We will, in all circumstances, safeguard personal data as set out in this Privacy Policy.

1. 4.4 Where we transfer personal data from inside the European Economic Area (the EEA) and/ or the United Kingdom (UK) to outside the EEA or UK, we may be required to take specific additional measures to safeguard the relevant personal data. Certain countries (including, where applicable, certain organisations self-certified under the EU-US Data Privacy Framework (DPF) or the UK Extension to the EU-US DPF) outside:
1. (a) the EEA, have been approved by the European Commission as providing essentially equivalent protections to EEA data protection laws; and
2. (b) the UK, have an adequacy decision in force under United Kingdom adequacy regulations.
   Therefore, no additional safeguards are required to export personal data to these jurisdictions. In countries which have not had these approvals, we will establish legal grounds justifying such transfer, such as EU Commission-approved model contractual clauses, the UK Information Commissioner approved standard contractual clauses or a vendor's Processor Binding Corporate Rules or other legal grounds permitted by applicable legal requirements.
2. 4.5 Please contact us through the “General Data Protection Enquiry” form below if you would like to see a copy of the specific safeguards applied to the export of your personal data.

Storage limits

1. 4.6 Our retention periods for personal data are based on business needs and legal requirements. We retain personal data for as long as is necessary for the processing purpose(s) for which the information was collected, and any other permissible, related purpose. For example, we may retain certain transaction details and correspondence until the time limit for claims arising from the transaction has expired, or to comply with regulatory requirements regarding the retention of such data. When personal data is no longer needed, we either irreversibly anonymise the data (and we may further retain and use the anonymised information) or securely destroy the data.

5 Your rights & contacting us

Marketing

1. 5.1 You have the right to ask us not to process your personal data for marketing purposes. From time to time, we will inform you if we intend to use your information for certain types of marketing activities, or if we intend to disclose your information to certain categories of third parties for such purposes. You can exercise your right to prevent such processing by not checking certain boxes on the forms we use to collect your personal data. You can also exercise the right at any time by contacting us as set out in the “General Data Protection Enquiry” form below.

Updating information

1. 5.2 We will use reasonable endeavours to ensure that your personal data is accurate. In order to assist us with this, you should notify us of any changes to the personal data that you have provided to us by contacting us as set out in the “General Data Protection Enquiry” form below.

Your rights

1. 5.3 If you have any questions in relation to our use of your personal data, you should first contact us as per the “General Data Protection Enquiry” form below. Under certain conditions, you may have the right to require us to:
   1. (a) provide you with further details on the use we make of your information;
   2. (b) provide you with a copy of information that you have provided to us;
   3. (c) update any inaccuracies in the personal data we hold (please see paragraph 5.2);
   4. (d) delete any personal data that we no longer have a lawful ground to use;
   5. (e) where processing is based on consent, to withdraw your consent so that we stop that particular processing (see paragraph 5.1 for marketing);
   6. (f) object to any processing based on the legitimate interests ground unless our reasons for undertaking that processing outweigh any prejudice to your data protection rights; and
   7. (g) restrict how we use your information whilst a complaint is being investigated.
2. 5.4 Your exercise of these rights is subject to certain exemptions to safeguard the public interest (e.g. the prevention or detection of crime) and our interests (e.g. the maintenance of legal privilege). If you exercise any of these rights we will check your entitlement and respond in most cases within a month.
3. 5.5 If you are not satisfied with our use of your personal data or our response to any exercise of these rights you have the right to complain to data protection authority in the country that you reside in or, the country of your place of work or the country where the alleged infringement took place. For data subjects in the UK, this is the Information Commissioner. For data subjects in the Netherlands, this is the Dutch Personal Data Authority, the Autoriteit Persoonsgegevens.

Contacting us

1. 5.6 Depending on where you are located, the “data controller” of your personal data processed by us under this Privacy Policy will be different. Please see here for a list of which branches will be data controllers in which countries.
2. 5.7 If you have any questions in relation to this policy, please contact us as per the “General Data Protection Enquiry” form below.

6 Cookies policy

1. 6.1 We use cookies on the websites. To find out more about how we use cookies, please see our Cookies Policy.

7 Changes to our Privacy Policy and/or Cookies Policy

1. 7.1 We may change how we process your personal data, the content of our websites and how we use cookies and consequently our Privacy Policy and our Cookie Policy may change from time to time in the future. If we change this Privacy Policy or our Cookies Policy, we will update the date it was last changed below. If these changes are material, we will indicate this clearly on our Websites.
2. 7.2 This Privacy Policy was last updated on 05.01.2024.

Annex

Use of personal data under EU data protection laws must be justified under one of a number of legal “grounds” and we are required to set out the grounds in respect of each use in this policy. We note the grounds we use to justify each use of your information next to the use in the “Uses of your personal data” section of this policy.

These are the principal legal grounds that justify our use of your information:

Consent:

where you have consented to our use of your information (you will have been presented with a consent form in relation to any such use and may withdraw your consent by contacting us as per the “General Data Protection Enquiry” form below.

Contract performance:

where your information is necessary to enter into or perform our contract with you.

Legal obligation:

where we need to use your information to comply with our legal obligations.

Legitimate interests:

where we use your information to achieve a legitimate interest and our reasons for using it outweigh any prejudice to your data protection rights.

Legal claims:

where your information is necessary for us to defend, prosecute or make a claim against you, us or a third party.